Chile: Tax authority publishes a Circular regarding transitional relief
The tax authority (SII) has released Circular No. 31 of 23 May 2018. It assures the transition relief provided regarding dividends paid by taxpayers under the partially integrated regime (PIS). The tax authority has also published Ordinance 470 and
See MoreCanada: Minister tables Notice of Ways and Means Motion to implement BEPS MLI
The Finance Minister, Bill Morneau, tabled a Notice of Ways and Means Motion in the House of Commons on May 28, 2018, for formalizing the Government's intention to introduce legislation that would enact the Multilateral Convention to Implement Tax
See MoreWorld Tax Brief: June 2018
Hong Kong Main corporate tax rate: On 16 May 2018, the Legislative Council passed the Inland Revenue (Amendment) Bill 2018 providing special tax measures including a 75% one-off reduction in profits tax, for the year of assessment 2017/18 is
See MoreArgentina: Government publishes General Resolution 4245/2018
On 16 May 2018, Argentina has published a General Resolution (4245/2018 of 15 May 2018) on their official website. The Resolution 4245 modifies the General Resolution 830/2000, which introduced income tax withholding on particular payments made
See MoreSlovenia publishes the clarification on MAP procedure
The Ministry of Finance of the Republic of Slovenia published the clarification on the Mutual Agreement procedure (MAP) on 7 May 2018, which is set out in the MAP scheme of the Slovenian Tax Treaty Network. The clarification provides detail in the
See MoreTransfer Pricing Brief: June 2018
Sweden: Financial services-Restriction on interest deduction: On 3 May 2018, draft legislation has been submitted to the Swedish parliament which includes safe harbour rule and limit to interest deduction. Under the proposed rules, the
See MoreHong Kong: Legislative Council passes the Inland Revenue (Amendment) Bill 2018
On 16 May 2018, the Legislative Council passed the Inland Revenue (Amendment) Bill 2018 providing special tax measures including a one-off 75% reduction in salaries tax, tax under personal assessment, and profits tax for the 2017/18 tax year,
See MoreTaiwan: MoF issues notice containing a list of jurisdictions regarding CbC reports
Taiwan's Ministry of Finance has (MoF) published a Notice , dated 27 April 2018, containing a list of countries or regions with which Taiwan has an agreement for the exchange of information, but not for the effectively exchange information on
See MoreNorway: Government releases the revised budget for 2018
The government of Norway released the revised Budget for 2018, which was approved by the Norwegian Cabinet on 15th May 2018. In the revised 2018 budget, the Government is proposing an increase of NOK 130 million in funding for the development
See MoreGermany: Federal Fiscal Court doubts the constitutionality of additional payment interest
On 14 May 2018, the Federal Finance Court (BFH) issued a decision suspending the additional default interest of 0.5% per month for unpaid taxes. The additional interest is considered unconstitutional. The simple penalty of 0.5% applies to every full
See MoreUS: IRS publishes new guideline for filing CbC reporting
On 18 May 2018, IRS released new guidance for filing the Form 8975 submitted by U.S. multinational enterprises (MNEs). When submitting Form 8975 and Schedules A (Form 8975), filers must attach at least two Schedules A (Form 8975) to the Form 8975.
See MoreKenya publishes draft income tax bill for 2018
National Treasury of Kenya has published the Draft Income Tax Bill 2018 for public comment. The draft Bill is intended to replace the current Income Tax Act with some certain provisions. Some of the main points are condensed as follows: Corporate
See MoreNew Zealand: Budget for 2018
On 17th May 2018, Finance Minister submitted New Zealand’s Budget for 2018 in the Parliament. The Budget process allows the government to: set its fiscal objectives in respect of revenue, expenditure, debt repayment and investment; maintain
See MoreLatvia: Cabinet Ministers approves a draft bill on Master and Local file
Recently, the Latvia Cabinet of Ministers has approved a draft law for the introduction of Master and Local file requirements in line with BEPS Action 13. Under the law, taxpayers resident in Latvia are required to submit Master file within 12
See MoreNetherlands publishes new transfer pricing decree
The Dutch Ministry of Finance published a new transfer pricing decree nr. 2018-6865 on 22 April 2018, which was published in the State Gazette on 11 May 2018. The Decree is in line with the outcomes of the Base Erosion and Profit Shifting (BEPS)
See MoreUS: IRS issues new advance pricing agreement (APA) template
On May 11, 2018, the IRS’s Advance Pricing and Mutual Agreement Program (APMA) issued a new template that taxpayers must use when requesting an advance pricing agreement (APA) under Rev. Proc. 2015-41, 2015-35 I.R.B. 263 (Rev. Proc. 2015-41).
See MoreCayman Islands: DITC released official guidance on the CbC reporting requirements
The Cayman Islands’ Department for International Tax Cooperation (“DITC”) released their official guidance on March 29, 2018 regarding the Country-by-Country (“CbC”) reporting requirements of entities that are resident in the Cayman
See MorePoland: Parliament enacts draft bill regarding supporting new investments
The lower chamber of the parliament enacted a draft bill regarding Supporting New Investments ( Ustawa o wspieraniu nowych inwestycji ) on 10th May 2018. The draft law will be presented to the higher chamber after some amendments. According to the
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